Gibbor Motors (Pty) Ltd is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, share, and protect your personal information in accordance with the Protection of Personal Information Act, 4 of 2013 (POPIA), the National Credit Act, 34 of 2005 (NCA), the Promotion of Access to Information Act, 2 of 2000 (PAIA), the Electronic Communications and Transactions Act, 25 of 2002 (ECTA), and all other applicable South African legislation.

Gibbor Motors does not knowingly collect or process personal information from persons under the age of 18. If you are under 18, please do not submit your personal information to us without the consent of a parent or guardian.

This policy applies to all personal information collected through our:

• •  Physical dealership at Unit 1, 20 Sefako Makgatho Road, Annlin, Pretoria
• •  Website at www.gibbormotors.co.za and any online platforms operated by Gibbor Motors
• •  Facebook, Instagram, and other social media advertising (including Meta Lead Ads and Automotive Inventory Ads)
• •  WhatsApp Business communications
• •  CRM and lead management systems (including Easy Quote by Easy Systems)
• •  Spotter and referral programmes
• •  Finance and Insurance (F&I) processes
• •  Any other channel through which you interact with Gibbor Motors

Gibbor Motors processes personal information on one or more of the following lawful bases: consent; performance of or entry into a contract; compliance with a legal obligation; protection of a legitimate interest of the data subject; necessity for the proper performance of a public law duty; or pursuit of the legitimate interests of Gibbor Motors, where not overridden by the rights of the data subject.

We are committed to collecting only the minimum personal information necessary for the stated purposes (data minimisation).

Information You Provide Directly

• •  Full name and surname
• •  Contact details including phone number, WhatsApp number, and email address
• •  Physical address and area of residence
• •  Employment information including employer name, occupation, and income details
• •  Financial information including monthly income, existing credit commitments, and affordability details
• •  Identity number (where required for F&I or NCA compliance purposes)
• •  Copies of identity documents, driver’s licences, bank statements, payslips, proof of residence, and other supporting documentation
• •  Vehicle preferences, trade-in details, and purchasing intentions
• •  Communication preferences

Special Personal Information

Certain information we collect (such as identity numbers and detailed financial records) may constitute special personal information under POPIA. We process such information only where required by law (NCA, FICA), where you have provided explicit consent, or where processing is necessary to establish, exercise, or defend a right or obligation in law.

Information Collected Through Advertising Platforms

• •  Information submitted through Meta (Facebook/Instagram) Lead Ad forms including name, phone number, email address, and qualifying responses
• •  Engagement data from Facebook and Instagram advertising including ad interactions, form submissions, and click behaviour
• •  Automotive Inventory Ad (AIA) interaction data

Information Collected Through Digital Channels

• •  Website usage data and browsing behaviour
• •  WhatsApp Business conversation records
• •  Social media interactions and messages
• •  Device information and IP addresses

Information Collected Through Third Parties

• •  Referral information from spotters, introducers, and referral partners
• •  Credit bureau information obtained during the finance application process (subject to your consent and NCA requirements)
• •  Information from vehicle finance providers and banks

Sales and Customer Service

• •  To respond to your enquiries about vehicles advertised by Gibbor Motors
• •  To assess your vehicle requirements and present suitable options
• •  To arrange test drives, viewings, and vehicle demonstrations
• •  To process vehicle sales and related documentation
• •  To follow up on outstanding enquiries and leads

Finance and Insurance (F&I) Processing

• •  To assess your affordability and eligibility for vehicle finance in compliance with the National Credit Act
• •  To submit finance applications to registered credit providers and banks on your behalf
• •  To present insurance and value-added product options
• •  To process and complete F&I documentation
• •  To collect and process identity documents, bank statements, payslips, and other supporting documentation

Marketing and Advertising

• •  To send you relevant marketing communications about vehicles, promotions, and offers
• •  To create and deliver targeted advertising on Facebook, Instagram, and other platforms
• •  To retarget website visitors and previous enquirers with relevant advertising
• •  To improve the relevance and effectiveness of our advertising campaigns

For existing customers, Gibbor Motors may send direct marketing in relation to similar products and services where contact details were obtained in the context of a previous transaction, provided that an opt-out was offered at the time of collection and is offered with each subsequent communication. For new prospects, explicit prior consent will be obtained before sending unsolicited electronic marketing communications, in compliance with POPIA Section 69.

Business Operations

• •  To maintain accurate records of customer interactions and transactions
• •  To manage our CRM system and lead pipeline
• •  To manage spotter and referral partner relationships and payments
• •  To verify customer information for fraud prevention, compliance, and risk management purposes
• •  To comply with legal, regulatory, and contractual obligations
• •  To resolve disputes and enforce agreements

Lead Ad Forms

When you submit a Facebook or Instagram Lead Ad form, your information (including name, phone number, email address, and responses to qualifying questions) is collected by Meta on our behalf and transmitted to Gibbor Motors. Our Lead Ad forms incorporate explicit consent mechanisms that comply with POPIA Section 69. By submitting a Lead Ad form, you consent to Gibbor Motors contacting you via phone, WhatsApp, or email in connection with your enquiry.

Meta Data Processing

Meta (Facebook Ireland Limited) processes data as a separate data controller in connection with its advertising platform. Gibbor Motors does not control Meta’s data processing practices. Please review Meta’s Privacy Policy at www.facebook.com/privacy/policy.

Custom Audiences

Gibbor Motors may use customer contact information to create Custom Audiences on Meta platforms for advertising purposes. Contact information is hashed before being uploaded to Meta, meaning the original data is not transmitted in readable form.

Automated Decision Making and Profiling

Meta’s advertising platform uses profiling and automated processing to deliver targeted advertising. Gibbor Motors does not make any legally significant decisions about data subjects based solely on automated processing. Under POPIA Section 71, you have the right to object to automated processing that significantly affects you.

Gibbor Motors uses WhatsApp Business to communicate with customers and leads on behalf of the dealership. Communications may be conducted by any authorised Gibbor Motors representative including sales staff, management, and support personnel. When you contact us via WhatsApp or when we contact you:

• •  Your WhatsApp messages and phone number will be stored in our business records
• •  Communications may be handled by any authorised Gibbor Motors team member
• •  Message history may be retained for up to 5 years for business record-keeping purposes, unless a longer period is required by law
• •  WhatsApp communications are subject to WhatsApp’s own privacy policy and terms of service

Where WhatsApp is used for direct marketing to prospects, Gibbor Motors will obtain explicit prior consent before sending unsolicited marketing messages in compliance with POPIA Section 69. You may withdraw consent at any time by replying “STOP” to any WhatsApp message or by contacting our Information Officer.

Gibbor Motors operates a spotter and referral programme. If you participate:

• •  Your personal information (name, contact details, and banking details for payment purposes) will be collected and stored
• •  Information about referred customers will be shared with us subject to those customers’ consent
• •  Referral fees and payments will be processed using your banking details
• •  Your participation records will be maintained for accounting and tax compliance purposes

Spotters and referral partners warrant that they have obtained the necessary consent from referred individuals before sharing personal information with Gibbor Motors. Spotters are required to provide referred individuals with information about Gibbor Motors’ privacy practices and their rights under POPIA at the earliest opportunity.

• •  Registered banks and vehicle finance providers (for finance application processing)
• •  Insurance companies and short-term insurers (for vehicle insurance processing)
• •  Value-added product providers (for warranty, service plan, and related products)
• •  Motor vehicle dealerships and manufacturers where relevant to your transaction
• •  Our CRM service provider (Easy Systems/Easy Quote) for lead and customer management
• •  Meta Platforms Inc. in connection with our advertising activities
• •  Terracloud, as our managed IT and cybersecurity service provider
• •  Website hosting providers, analytics providers, and digital service providers
• •  Legal and compliance advisors where required
• •  SARS and other regulatory authorities where legally required
• •  Law enforcement authorities where required by law

We do not sell your personal information to third parties.

Operator Agreements

Where third parties process personal information on behalf of Gibbor Motors (as operators under POPIA), Gibbor Motors maintains or seeks to maintain appropriate written agreements with such operators in accordance with POPIA requirements.

• •  Secure storage of physical documents with restricted access
• •  Password-protected digital systems and CRM platforms
• •  Encryption of sensitive data where feasible
• •  Restricted access to personal information on a need-to-know basis
• •  Regular review of access controls and security practices
• •  Employee awareness of data protection obligations
• •  Managed cybersecurity and IT security services provided by Terracloud

Data Retention

Data Breach Notification

In the event of a security compromise affecting personal information, Gibbor Motors will take reasonable steps to investigate and, where required by law, notify affected individuals, relevant authorities, and the Information Regulator as soon as reasonably possible after discovery of the compromise.

Cross-Border Processing

Certain service providers (including Meta, cloud storage providers, and other digital platforms) may store or process personal information outside South Africa. Where this occurs, Gibbor Motors takes reasonable steps to ensure compliance with POPIA Section 72.

• •  The right to be notified when your personal information is collected
• •  The right to access your personal information held by us
• •  The right to request correction of inaccurate, incomplete, or outdated personal information
• •  The right to request deletion or destruction of your personal information (subject to legal retention requirements)
• •  The right to object to the processing of your personal information
• •  The right to object to direct marketing use of your personal information
• •  The right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects
• •  The right to withdraw your consent to processing at any time
• •  The right to lodge a complaint with the Information Regulator of South Africa

To exercise any of these rights, contact our Information Officer, Clifford Smith, at admin@gibbormotors.co.za or via WhatsApp on 082 569 4221.

You have the right to opt out of direct marketing communications at any time by:

• •  Replying “STOP” or “OPT OUT” to any WhatsApp or SMS marketing message
• •  Contacting our Information Officer at admin@gibbormotors.co.za
• •  Unfollowing or blocking our social media accounts

Once you have opted out, we will cease sending you direct marketing communications and update our consent records accordingly.

Our website (www.gibbormotors.co.za) uses cookies and similar tracking technologies to improve your browsing experience and to analyse website traffic.

Gibbor Motors may utilise a cookie consent management mechanism on its website to obtain consent for non-essential cookies where required by applicable law. Visitors may manage cookie preferences through their browser settings and any cookie consent tools made available on the website.

• •  Essential cookies: necessary for the website to function and cannot be switched off
• •  Analytics cookies: help us understand how visitors use our website
• •  Marketing cookies: used to deliver relevant advertising, including Meta Pixel for Facebook and Instagram advertising purposes

Gibbor Motors maintains a PAIA Manual in accordance with the Promotion of Access to Information Act, 2 of 2000. The PAIA Manual is available:

• •  Upon request at our dealership at Unit 1, 20 Sefako Makgatho Road, Annlin, Pretoria
• •  Upon request via email at admin@gibbormotors.co.za
• •  On our website at www.gibbormotors.co.za (when published)

Gibbor Motors reserves the right to update this Privacy Policy from time to time to reflect changes in our business practices, legal requirements, or the platforms and services we use. The most current version will always be available on our website at www.gibbormotors.co.za and upon request at our dealership.

Where material changes are made, Gibbor Motors will notify affected data subjects by means of a notice on our website and, where reasonably practicable, by direct communication. Updated policies will indicate the effective date of the changes.